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5
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- The Park’s first factory, Balan Cellulose and Chemical Manufacturing Company, began operations in 1908.
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- The Thruway made it possible to transport heavy freight between Tintagel Coast and the rest of the Peninsula. As part of the agreement, Balan pledged that use of the port and the Eamont Thruway would remain open to Aglovale “in perpetuity,” in exchange for a nominal annual fee. Aglovalean traders made extensive use of the port facilities for import and export, and the Thruway remains to this day the only land route between the seaport and Aglovale.
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6.Most of these products were exported through Tintagel port. The harbor protruded into deep waters, allowing large vessels to dock safely. Its efficient infrastructure increased the port’s size and capacity and became a major hub for trade and transport. Other harbors along the Dozmary Sea, especially in R, saw a decline in revenues. The villages and towns along R’s coast lost their economic mainstay, and the subsequent economic dislocation in R triggered tensions in the Peninsula
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- Until the early 1950s, the Belt was universally recognized as part of the territory of Balan.
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- Ragnell strenuously denied these claims, declaring that “by its saber-rattling” Balan was recklessly risking devastating consequences for the region.
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7
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Toxic chemicals and heavy metals from damaged factories leaked into the soil, polluting aquifers, inland streams, and the ocean. The pollution decimated local fish stocks, destroying the livelihoods of many families living along Tintagel Coast.
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8 & 9. At the outset of the fighting, King Norton IV of Aglovale proclaimed that his country would remain neutral, so long as its use of the port facilities and the Eamont Thruway was not threatened. The two belligerents accordingly respected Aglovale’s right of access to the sea, although damage to the port infrastructure impeded importation of raw materials into and exportation of finished products from Aglovale.
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- In her coronation speech, the young monarch declared: “Years of conflict between our neighbors have left the Gais Peninsula deeply scarred. Under the wise leadership of His late Majesty my father, Aglovale has avoided entanglement in that conflict. My government now offers its services to steward the way to lasting peace. I dedicate my reign to that goal.”
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10
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10 & 11. The Treaty was registered with and published by the United Nations Secretariat. The parties committed to “demilitarization of the Belt,” “cessation of hostilities,” and restoration of “friendly relations” among them. Balan retained sovereignty over the Belt, but agreed to lease the entire territory of the Belt to Ragnell for a specified annual payment.
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As part of these efforts, Ragnell licensed several companies to construct waste management facilities in the Park and required that corporations operating in the area commit to environmentally sustainable practices.
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- For the duration of the lease, Ragnell assumed responsibility for maintenance of public order and provision of government services. Balan and Ragnell guaranteed Aglovale unimpeded use of the seaport and the Eamont Thruway, and Aglovale agreed to monitor the other parties’ compliance with the terms of the Treaty.
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- The RPP was created with a central manifesto of deregulating commercial activities, strengthening Ragnell’s military and economic power, and protecting Ragnellian interests in the Belt.
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- The RPP gradually gained a following, and by the mid-1980s it was one of the country’s two major political parties.
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14 & 15. For its part, Aglovale subsidized infrastructure development and environmental projects on Tintagel Coast and funded periodic renovation of the port facilities.
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- As part of this project, several new branch lines were added, extending the system into central Balan and Aglovale, and the only tunnel mouth within the Belt, “Nant Gateway,” was modernized.
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- Among the products were: Sterilization wraps, protective equipment, labware and drug delivery components, syringes and blood oxygenators, and packaging films.
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18
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18 & 19. Neither Ragnell nor Aglovale has ratified this Convention. However, both States have repeatedly and publicly committed to promoting environmental protection through domestic measures.
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- As a result, factories operating in both countries were incentivized, by significant tax benefits and the prospect of expanded civil liability, to manufacture products which were biodegradable and reusable.
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- Neither Ragnell nor Aglovale has ratified this Convention. However, both States have repeatedly and publicly committed to promoting environmental protection through domestic measures.
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16 & 17. As the Park’s activities expanded, the population of Tintagel Coast also increased.
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17
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- He gained strong support from Ragnellians who were concerned that, following the withdrawal from the Belt, Balan would impose onerous environmental and labor regulations on businesses continuing to operate there. Vortigern promised that, if elected, he would demand that Balan not “force Ragnellian investors in the Belt into a disabling economic straitjacket.” He stated that his administration would find “creative legal mechanisms” to protect Ragnell’s economic interests after 2023
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- In his speech, Balan’s Prime Minister called on his R counterpart to initiate discussions to prepare for R’s orderly withdrawal from the Belt upon the termination of the lease. In their own remarks, and at a press conference that afternoon, R’s and A’s representatives offered no response. When asked for a reaction, the Foreign Minister of A, said: We are here to enjoy the day and celebrate the success of the Treaty. This is neither the time nor the place to discuss its end
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24.Following the election, his rhetoric relating to the Treaty intensified.
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24 & 25. With Vortigern’s election, UAC’s membership increased within Balan, and its tactics began to shift from informational campaigns to sporadic physical attacks and cyber-attacks against factories owned by R in Tintagel Park and R’s law enforcement units in the Belt. The frequency and severity of these incidents increased sharply over the next several years.
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- Ragnell repeatedly called on Balan to take effective measures to prevent violence committed or instigated by UAC. Balan responded that it was already undertaking such efforts, including police raids on UAC clubs in Balani cities and arrests of members believed to have been involved in incidents in the Belt. Balan agreed to take the additional step of inspecting the contents of commercial vehicles crossing into the Belt and confiscating any weapons or other forms of contraband
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14
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- Tintagel Park’s biomedical plants worked around the clock to meet the increased demand for these items. These expanded manufacturing operations created additional waste at the rate of approximately 10,000 metric tons per month. The Plastics Conglomerate established one of only two dedicated treatment facilities in the region with the capacity to process both contaminated and non-contaminated plastic medical waste.
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- He said: “I am grateful to Prime Minister Dalfer for his acknowledgment that UAC violence is coming from Balan. But he and his government must do much more. They cannot be passive in the face of the UAC terrorist attacks. Failure to stop them is a violation of the Treaty. If the government of Balan does not care about protecting property and saving lives, I do. If they cannot or will not act, I will.”
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- I join Vortigern in condemning UAC’s attacks. However, the Treaty limits our authority to act in the Belt. Let us hope that the President is not fabricating an excuse to disregard R’s most fundamental obligation under the Treaty. There is no justification for R’s refusal to affirm that it will honor its commitments. R must leave the Belt on 16 October 2023, and not one day later. To do that, Vortigern’s government must begin now to prepare for an orderly withdrawal.
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- UAC fighters had well-established command and control structures and carried arms openly. They took positions throughout the Belt, attacking R’s forces and facilities owned by R corporations in the Park. UAC’s arsenal was limited, consisting chiefly of improvised explosive devices and grenade launchers, personal defense weapons, and assault rifles. Nonetheless, its guerrilla warfare tactics including ambushes and sabotage raids continued unabated.
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- Communications admitted that “We are unable to establish control over the Belt.” UAC fighters had well-established command and control structures and carried arms openly. They took positions throughout the Belt, attacking R’s forces and facilities owned by corporations. UAC’s arsenal was limited, consisting of improvised explosives and grenade launchers, personal defense weapons, and assault rifles. But, its guerrilla warfare tactics including ambushes and sabotage raids continued unabated
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- Fighters were provided basic food and shelter, and their treatment met or exceeded relevant international standards.
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Commnications admitted: “We are unable to establish control over the Belt” UAC has well-established command and control structures and carried arms openly. They took positions throughout the Belt, attacking R’s forces and facilities owned by R in the Park. UAC’s arsenal was limited, consisting of improvised explosive devices and grenade launchers, personal defense weapons, and assault rifles. Nonetheless, its guerrilla warfare tactics including ambushes and sabotage raids continued unabated.
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- President Vortigern communicated to the leaders of both Balan and Aglovale that the situation had reached “a degree of seriousness, and of harm to our citizens and our enterprises, that requires me to take firm and decisive action. And regretfully, it appears that we must do this alone. So be it.”
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- “Operation Shining Star,” a “limited and temporary military campaign” with the declared aims of “wiping out the UAC terrorist cells on Tintagel Coast, saving lives, and restoring regional prosperity.” Armored vehicles and Ragnellian military battalions entered the Belt for the first time since the end of the Clarent War.
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- He stated, “The actions of a group of thugs, which Balan is doing all in its power to quash, do not justify this use of armed force, which endangers all we have worked to build on Tintagel Coast.” Queen Clarine appeared on national television, imploring Vortigern to end the operation and calling on both sides to “commit to a prompt diplomatic resolution, preventing further violence and bloodshed.”
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- Foreign Minister Laudine announced, “because of the increasing risks to our men and women in uniform, our peacekeepers will return home from the Clarent Belt immediately and will not be redeployed until further notice.”
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- President Vortigern assured his Parliament that the military operation would be “swift and decisive,” and called on the remaining Ragnellians in Tintagel to “continue to operate the factories and waste management facilities in the Park to the maximum extent you can, while keeping yourselves and your families out of harm’s way.”
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34.A circulated a draft resolution expressing “grave concern” over the Belt, calling on R to cease military operations, and seeking UN peacekeeping force to restore order.Balan presented a summary of the situation, citing exponential increase in property destruction and casualties.4 other states claimed the intelligence showed that “R’s intervention was Vortigern’s desire to pretext justifying withdrawal from the Treaty.” 12 states voted in favor, but it was vetoed by 3 permanent members.
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- Commnications admitted: “We are unable to establish control over the Belt” UAC has well-established command and control structures and carried arms openly. They took positions throughout the Belt, attacking R’s forces and facilities owned by R in the Park. UAC’s arsenal was limited, consisting of improvised explosive devices and grenade launchers, personal defense weapons, and assault rifles. Nonetheless, its guerrilla warfare tactics including ambushes and sabotage raids continued unabated
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- Ragnell’s forces increased their hold over parts of the Belt. More than 400 UAC fighters were captured, and were held at Fort Caerleon, a makeshift detention center within the Belt some distance from the areas of active combat. They were provided basic food and shelter, and their treatment met or exceeded relevant international standards.
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- On 15 October 2021, the Foreign Ministry of Ragnell issued a statement advising its nationals to avoid non-essential travel to the Belt and urging those already there to “consider departing the region immediately” for their own safety. In the following two weeks, about 2,000 Ragnellians left the Belt using the Eamont Thruway.
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- On 15 November 2021, the main waste treatment plant of The Plastics Conglomerate was the site of day-long fighting between UAC units and Ragnell’s forces. During the encounter, the central floor collapsed, rendering the facility inoperative. Company experts estimated that it would take at least eight months to restore it to full function even without the threat of ongoing hostilities.
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- Plastic waste such as non-biodegradable and unsorted synthetic polymers including polyethylene(PE) & polyvinyl chloride(PVC), began to accumulate in Tintagel Park and the port area. Large accumulations of medical waste were found to be contaminated by the bacterial pathogens Clostridioides difficile and methicillin resistant Staphylococcus aureus. Industry experts predicted that continued fighting in the Belt “could trigger an unprecedented regional environmental and public health calamity”
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- Ragnell made several requests to transfer the waste for processing in Aglovale, the location of the only other suitable facility in the Peninsula.
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40
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- Ragnell & Aglovale committed to resume talks on December 27, 2021.
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- Balani military organized a convoy of trains, buses, and medical vehicles to carry out the operation, and positioned armed sentries at Nant Gateway to protect civilians enroute to safety. The guards were ordered not to engage in any capacity, except in direct response to an attack on the convoy.
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- He called on “all belligerents to refrain from any military activity that might endanger the unimpeded passage of civilians along the Eamont Thruway.” Simultaneously, Dalfer asked Aglovale to intervene in the worsening situation, “to protect the Belt, to bring a halt to Vortigern’s unprovoked invasion, and most importantly to ensure that the Belt is returned to Balan in accordance with the Treaty.”
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She relayed what she said was reliable intelligence that dozens of UAC fighters were making their way along the Eamont Thruway to launch a surprise attack on Ragnell’s forces in the Belt.
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- A military spokesperson released a statement noting that over 30 UAC fighters had been killed in the bombing raid and that no civilians had been harmed. He stressed that “the operation was necessary not only to prevent an imminent escalation, but to end the ongoing use of the Eamont Thruway for smuggling arms and transporting UAC hooligans into the Clarent Belt to continue their campaign of violence and terrorism.”
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- She pointed out: A had used the destruction of Thruway took the conflict to a dangerous level. Dozens of A civilians, as well as Balanis and Rs, who had not been able to escape from the Park, were now isolated and extremely vulnerable.Transporting basic necessities and humanitarian aid has been nearly impossible.The attack on the humanitarian corridor was an act of collective punishment that is unacceptable under IHL. We are deeply concerned and demand an explanation.
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- Foreign Minister Laudine, in a note verbale informed her R counterpart that “the waste management negotiations scheduled to resume tomorrow are cancelled,” because “the unnecessary, indiscriminate, and inhumane bombing of Nant Gateway requires us to rethink any future cooperation with R. At the very least, we cannot sit down with the representatives of a government responsible for such an outrage unless and until there is a complete halt of Ragnell’s military activities in the Clarent Belt.”
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- Etna is a party to the Basel and Stockholm Conventions. Etna committed to dispose of the waste in an environmentally sound manner in accordance with those treaties and declared that its treatment facilities were appropriately equipped. As required by Article 11 of the Basel Convention, the agreement was transmitted to the Convention’s Secretariat.
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- Shipments began and continued until almost all of the waste had been removed from Tintagel Coast. Because of the limited number of Ragnellian workers still in the Park and the urgency of removing the material, Ragnell ordered UAC detainees in Fort Caerleon to help load the waste onto ships. Ragnell paid the detainees wages commensurate with the nature of the work, and provided them with basic safety gear, including masks and gloves.
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- Report stated that Etna’s primary treatment sites “are not equipped to handle shipments from R, and Etna will be left with no alternative but to engage in unsustainable & environmentally harmful practices, including incineration and dumping of potentially infectious plastic waste into open landfills and the ocean.” Etna rejected these statements, and while subsequent ILSA reports indicate that some incineration and landfill and ocean disposal did take place, exact quantities remain unknown.
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- She added: We are extremely disappointed that A decided to ignore its obligations under the Treaty and refused to cooperate with us. The untreated waste in the Park became an acute problem only because of that incomprehensible decision. We were left with no other option, and the arrangement with Etna, although not ideal, was the best one open to us. To be clear, sending the waste to Etna for processing and disposal was fully in compliance with our obligations under Part IV of the Treaty.
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- A Balani worker who claiming to have details of the situation inside Compound Ardan reported to R’ that all the occupants were UAC fighters engaged in active combat. The informant provided a map of the Compound and cellphone photographs seeming to show that UAC activities were concentrated in 4 buildings, while another smaller structure – Warehouse 15 – was being used to store weapons and ammunition. This intelligence was consistent with drone footage collected by R the preceding month.
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47
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49.
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- The Minister said: Since the Belt is under the effective control of a hostile army, Ragnell is responsible as a belligerent occupier for the wanton killing of civilians.” She also claimed that detainees’ employment in hazardous conditions in connection with the loading of the contaminated medical waste, and their subsequent forceful transfer into Ragnell’s territory and internment in a penitentiary, “are also violations of the Geneva Conventions and customary international humanitarian law.
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- He added: Temporary employment of the captured UAC fighters and their transfer to Camlann, were both necessary to ensure safety of the region and them. It complied with all of R’s obligations under IHL. Note stated that the Ministry had allowed visitation by the ICRC to both Fort Caerleon and Camlann Correctional Center, and that the attack on Compound Ardan complied with international law as it was necessary and proportionate based on the information known to the commanders on the ground.
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- The Parliament debated, but ultimately rejected, a bill instructing the President to denounce the Treaty, expressing “hope that [it] may still serve as the foundation for future agreements among the parties.”
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- Governments of Aglovale and Balan released a joint statement declaring their “decisive repudiation” of Ragnell’s attack on Nant Gateway and Compound Ardan and calling for the immediate return of Balani detainees to the Belt, which the statement called “occupied Balani territory.” The statement condemned “Vortigern’s war of aggression in the Belt,” Ragnell’s parliamentary resolution, and the interruption of operations at the seaport.
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(See fact 53 to 55)
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- He said: A is attempting to force us to accept an untenable situation, with sanctions that are illegal and morally unacceptable. At this difficult time, let me assure the brave citizens of R that our economy and our way of life will survive. We will not surrender to this outrageous aggression. Our foreign partners and business allies will not tolerate it either. They will continue to trade with us, in a broad-based international condemnation of what we can only describe as bullying
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- Aglovale seized Prydwen Place, the Aglovalean summer home of Kay Ector, a Ragnellian national and a primary donor to the RPP. Ector denied these allegations and filed suit in civil court in Aglovale to overturn what he called “this act of expropriation.” The trial court dismissed the suit, holding that the seizure was valid under the statute, and that the law itself was consistent with the Constitution. On an emergency appeal, the Aglovalean Supreme Court affirmed the dismissal.
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- The Ambassador of Balan to Ragnell personally delivered a letter to President Vortigern demanding initiation of negotiations for the transition of the Belt to Balani control, in accordance with Article 18.1 of the Treaty. It noted that these discussions should have begun two months earlier, as the Treaty required. The letter warned that failure to start negotiations immediately “could trigger a far larger and more extended conflict between our two countries.”
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- My government will begin discussions with B concerning the future of the Belt if B provides us: (a) peace restored to the Belt, UAC members disarmed & membership in UAC criminalized; (b) trinational committee manages Park and ensures that R-owned businesses operate without interference; (c) legal regimes governing R-owned businesses in the Park remain identical to the ones during the term of the Lease; (d) A’s peacekeeping forces return to the Belt to monitor compliance with these conditions
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- The same day, Aglovale announced that it would not resume its monitoring presence in the Belt unless and until it determined that its peacekeepers would not be at risk of harm from continuing violence.
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61
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- On 13 July 2022, after negotiations failed to produce an agreement, Ragnell filed an Application with the Registry of the Court instituting proceedings against Aglovale, invoking Article 41 of the Treaty as the basis for the Court’s jurisdiction, and claiming that the sanctions against Ragnell and its nationals were illegal.
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62.
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- On 15 August 2022, the Court entered an Order recommending that the parties draft a Statement of Agreed Facts. The parties stipulated that Aglovale would appear as Applicant and Ragnell as Respondent, without prejudice to any question of burden of proof.